The governing bodies of the International Oil Pollution Compensation Funds (IOPC Funds) held sessions from Tuesday 4 to Friday 7 November 2025 at the headquarters of the International Maritime Organization (IMO) in London. Sixty-eight 1992 Fund Member States, including 24 Supplementary Fund Member States, three observer States and 16 observer organisations, attended sessions of the 1992 Fund Assembly, the 1992 Fund Executive Committee and the Supplementary Fund Assembly. This meeting was held in person, complemented by remote participation, in fully hybrid format for the first time.
1992 Fund Executive Committee (85th session), Chaired by Małgorzata Buszyńska (Poland)
Information was provided to the 1992 Fund Executive Committee on all open incidents involving the IOPC Funds. In particular, recent developments in the following incidents were reported.
Terranova – The Philippines (July 2024)
The 1992 Fund and Steamship Mutual, the insurer of the Terranova, continue to work closely to facilitate the processing of claims for compensation arising out of the incident. At the time of the November 2025 meeting, the Claim Submission Offices (CSOs) in Bataan and Cavite had received 34 832 claims from affected municipalities in those areas as well as in Bulacan. These claims are being progressively registered in the IOPC Funds’ claims-handling system, with 21 028 claims registered to date, amounting to a total value of
PHP 735 943 277. Steamship Mutual have submitted claims for pollution response, clean-up and oil removal totalling USD 12 642 785. These claims are currently being registered and will then be assessed. Additional claims related to the wreck removal operation are still being finalised but are estimated at USD 8 745 000.
Marine Honour – Singapore (June 2024)
At the time of the Committee session, the CSO had registered 592 claims, which totalled an amount of approximately SGD 73 million. Out of that number, 248 had been approved. QBE Insurance (Singapore) Pte Ltd (QBE), the insurer of the Marine Honour, had submitted claims for clean-up costs, the costs of mitigating the risk of further pollution from the Marine Honour, and the management of these operations. These claims total SGD 7 700 522 and USD 21 383 729. In March 2025, the 1992 Fund had agreed to make a provisional payment of USD 11 million to QBE. The Fund has now also approved amounts totalling SGD 4 432 265 and USD 16 123 610 in relation to QBE’s claims for oil spill response and prevention, and expert fees. Assessments of QBE’s remaining claims are ongoing.
Singapore government agencies have submitted claims amounting to SGD 18 413 529 for response costs, of which the 1992 Fund has approved SGD 2 848 067. The remaining amounts are under assessment. The CSO has also received claims from 137 fishers in Johor (Malaysia) for property damage and economic loss, totalling MYR 609 762, and the 1992 Fund has engaged fisheries experts from the Universiti Malaysia Terengganu to assess the claims. In light of the anticipated payments of compensation required in this incident, the 1992 Fund Assembly decided to levy 2025 contributions of £15 million to the Marine Honour Major Claims Fund, payable by 1 March 2026.
Gulfstream, Trinidad and Tobago (February 2024)
In early May 2024, the Solo Creed tug was arrested in Angola for breaching the boundaries of a number of oil field exclusion zones. The vessel was placed under arrest by the Angolan authorities and the tug remained at anchor in Luanda Bay, Angola. In November 2024, the tug escaped from arrest and remains at large. There remains a lack of any definitive information regarding the true ownership of the barge Gulfstream at the time of the incident, due in part to the submission of unverified documentation to the registry.
At the time of the meeting, the 1992 Fund’s Focal Point Office (FPO), established in Trinidad in June 2024, had so far received 357 claims, totalling USD 48.5 million. These claims relate to clean-up operations undertaken in Tobago, Bonaire and to fisheries. These claims are being assessed by the 1992 Fund’s experts. As of November 2025, some 236 claims had been assessed, and payments totalling TTD 29 803 751 had been made. The 1992 Fund continues to engage with potential claimants and the authorities in Trinidad and Tobago to ascertain the extent of their losses.
Princess Empress, the Philippines (February 2023)
In September 2025, the Director and two Claims Managers visited the Philippines and met with a number of government agencies. The Director and his team encouraged all stakeholders to submit their claims as soon as possible to allow sufficient time for assessment and settlement, and to avoid the time-bar deadline of 28 February 2026. At the time of the Committee session, the CSO established by the 1992 Fund and the Shipowners’ P&I Club had registered a total of 40 807 claims, mainly in the fisheries sector, amounting to PHP 3 878.92 million. The 1992 Fund and the Shipowners’ P&I Club had approved the assessment of 38 930 claims. Of these, 34 063 claims had been paid and 3 512 claims had been rejected. In light of the anticipated payments of compensation required in this incident, the 1992 Fund Assembly decided to levy 2025 contributions of £5 million to the Princess Empress Major Claims Fund, payable by 1 March 2026;
Bow Jubail (Netherlands, June 2018)
The 1992 Fund was notified of the limitation proceedings brought against the shipowner within three years from the date when the damage occurred. Consequently, the IOPC Funds informed those claimants who only notified the 1992 Fund of their claims, that they should have commenced a lawsuit by 23 June 2024, to protect their rights. At the time of session, the 1992 Fund’s experts had commenced assessing the 44 claims totalling EUR 30.8 million, USD 1.92 million and NOK 152 070 that were filed with the limitation fund assessor in August 2024. Twenty claims totalling EUR 9.3 million have been assessed, with nineteen claims amounting to EUR 5.82 million paid. Four further offers of payment have been made and await acceptance. Work will soon commence on the assessment of some of the largest claims submitted by the Dutch State and the Port Authority. In light of the anticipated payments of compensation required in this incident, the 1992 Fund Assembly decided to levy 2025 contributions of £6.5 million to the Bow Jubail Major Claims Fund, payable by 1 March 2026.
1992 Fund Assembly (30th session), Chaired by François Marier (Canada), and Supplementary Fund Assembly (22nd session), Chaired by Andrew Angel (United Kingdom)
During their simultaneous sessions, the governing bodies took several decisions and noted a wide range of information provided in relation to compensation matters, treaty matters, financial policies and procedures and Secretariat and administrative matters.
Budgetary matters and assessment of contributions
The 1992 Fund Assembly adopted an administrative budget for the 1992 Fund of £5 916 097 for 2026 and decided to levy 2025 contributions to the General Fund of £8 million, payable by 1 March 2026. Together with the decisions to levy contributions to the Bow Jubail, Marine Honour and Princess Empress Major Claims Funds, the total levy amounted to £34.5 million. It also decided to increase the working capital of the 1992 Fund to £19 million in the budget year 2026.
The Supplementary Fund Assembly adopted an administrative budget for 2026 of £74 000 (including the management fee of £46 000 payable to the 1992 Fund, and the cost of the external audit) and decided to maintain the working capital of the General Fund at £1 million.
Fulfilment of obligations by Member States to submit oil reports and ensure payment of contributions
At the time of the meeting, all Supplementary Fund Member States had completed the submission of 2024 oil reports. However, 31 reporting entities (30 Member States plus one autonomous partner) of the 1992 Fund had yet to submit their 2024 reports. A total of eight Member States of the 1992 Fund have outstanding reports for five or more years, while two States have never submitted reports despite having been Members of the 1992 Fund for many years. The governing bodies were pleased to note that, at the time of its November 2025 session, 99.58% of 1992 Fund contributions levied to date had been paid and no contributions to the Supplementary Fund were outstanding.
As instructed at previous sessions, the Director has continued to implement measures to encourage States to fulfil their obligations under the 1992 Conventions. In September 2025, 16 States were notified that 1992 Fund Assembly Resolution No12 was applicable to them. Under that Resolution, payment of compensation to Government authorities in a State affected by an incident would be postponed if they had outstanding oil reports or unpaid contributions for more than two years. The Director has also continued to successfully apply 1992 Fund Assembly Resolution No13, which authorised him to issue invoices based on estimates, including retrospectively in relation to past periods, when no oil reports had been submitted.
Potential impact of international sanctions on the international liability and compensation regime
The Secretariat again highlighted the issues, risks and dangers and the potential impact of international sanctions on the international liability and compensation regime. Several delegations expressed deep concern regarding the increasing risks posed by the expansion of the so-called ‘shadow fleet’ or ‘dark fleet’ and by vessels engaged in unsafe or uninsured operations, often in connection with the transport of sanctioned oil.
The Secretariat took the opportunity to remind Member States of their obligation under the 1992 CLC, to ensure that tankers had a CLC certificate and noted that failure to do so might result in Flag State liability. Attention was drawn to IMO Resolution LEG.1/Circ.16.
Risk of uninsured and unsafe ships
The delegation of Türkiye presented a document regarding the legal basis and importance of the insurer’s liabilities and the difficulties encountered in verifying insurance policies, and encouraged Member States to share lists of reliable or reputable insurers, if available. Several delegations supported the proposal to share more information about reliable insurers amongst Member States, whilst others noted that there were already provisions available within all the IMO liability and compensation conventions, and within the revised guidelines found in IMO circular LEG.1/Circ.16 . Several delegations expressed their preference for such matters to be dealt with in the context of the regulatory scoping exercise to identify gaps in the IMO instruments, currently being undertaken within IMO, to avoid any issues of duplication.
Development of a guidance document — Procedures for determining whether a ship falls under the 1992 Civil Liability Convention or the 2001 Bunkers Convention
Following a number of meetings with industry representatives to discuss a standard procedure to determine when a ship that can serve both as an oil tanker and as a chemical tanker, ceased to be a ‘ship’ under the 1992 CLC, the Director proposed that such guidance be issued as a footnote in the IOPC Funds’ publication ‘Guidance for Member States, Consideration of the definition of ‘ship’’. The governing bodies agreed with the Director’s proposed interpretation of the term ‘residues’ and decided upon the exact wording of the footnote. The Director confirmed that the Secretariat would update the relevant publication with the agreed text and announced that the new version would be published on the IOPC Funds’ website by early December 2025 with printed copies being made available shortly thereafter.
2010 HNS Convention
The Secretariat reported that it had continued to take opportunities to promote the entry into force of the 2010 HNS Convention and had been working with interested States. Belgium, Germany, the Kingdom of the Netherlands and Sweden reiterated their earlier commitment to take the necessary steps to deposit their instruments of ratification of the 2010 HNS Convention concurrently. The delegation of Finland also reported that it had obtained the necessary confirmation from their Government to allow it to accede to the 2010 HNS Convention immediately after the other four States. The 1992 Fund Assembly warmly welcomed these updates and the accelerating momentum towards the entry into force of the 2010 HNS Convention, which seems likely in 2027, noting that this will significantly strengthen the international liability and compensation regime.
The Secretariat reported on the various tasks it needed to undertake before entry into force of the Convention and the 1992 Fund Assembly approved an appropriation of £548 200 in the 2026 budget for the 1992 Fund to cover the costs for those preparations and other administrative tasks in respect of the HNS Fund.
Dates and format of future meetings
It was decided that the next sessions of the governing bodies would be held during the weeks of 4 May and 19 October 2026.
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Note: The above is a summary of key aspects of the sessions held and does not reflect the sessions in full. A comprehensive Record of Decisions may be obtained via the Document Services section of the IOPC Funds’ website at www.iopcfunds.org.
Thanks to Raymond Bayor, IOPC Funds Information Officer for the summary
Photo Credit: Alistair Veryard Photography ([email protected] )
